UK horseracing keeps confusing FRAs for affordability checks

By | July 8, 2026

Responses from the gambling sector have poured in after yesterday’s UK Gambling Commission announcement that Financial Risk Assessments (FRAs) are still on track to be implemented. 

And while criticism has expectedly mounted, a glaring issue kept rearing its head – some stakeholders have apparently missed the brief that the Commission has moved on from affordability checks.

The British Horseracing Authority’s (BHA) response to the Commission announcement is the most explicit example of that.

Brant Dunshea, Chief Executive Officer of the BHA, made a clear mistake in his statement addressing the upcoming changes: “We are hugely disappointed that the Gambling Commission will implement affordability checks which will have severe financial implications for British racing and the UK economy and subject racing bettors to unwarranted levels of intrusion.”

As the spokesperson for an industry that is still trying to recover financially from the COVID-19 pandemic, and wants to convince the government that FRAs will cause even more damage, Dunshea’s blunder will not do horse racing any favours in its attempts to sound authoritative.

In his defence, however, he is obviously aware of what FRAs are, given that further into his statement he said: “The pilot has highlighted issues that must be resolved, including Credit Reference Agencies producing different results for the same customer.”

Credit reference agencies will indeed be a core element for every FRA, and the difference in how they use datasets and methodology to assess individual customers has been one of the main talking points of FRA critics.

Still, affordability checks – first recommended in the 2023 Gambling White Paper, and then dropped by the Commission in favour of the more ‘light-touch’ FRAs – still get mixed up with their counterpart throughout the rest of the BHA statement.

Looking at the statement’s editor notes, the Authority brought forward a number of past surveys and reports to prove a point that the horseracing industry will continue to suffer if the Commission sees its plans through.

The only issue here is that some of the supporting evidence, such as a Regulus Partners report that the industry will lose around £250m in revenue by the end of the decade, are actually referring to the impact of affordability checks, and not FRAs.

Perhaps the mishap stems simply from muscle memory – the policy debate has for years revolved around affordability checks, with FRAs entering the public discourse some time later.

Perhaps it is a failure on the Commission’s side to communicate the developments in a clear manner. In Dunshea’s words: “It is also essential that the Commission significantly improves its communication with stakeholders as this policy now moves forward to the implementation phase as there has been a distinct lack of information provided throughout the latter stages of the process.”

One thing is for certain, however – the implementation of FRAs is imminent, which has seemingly created an even bigger divide between industry and regulator, at a time when the UK gambling sector is already faced with a list of hurdles on the back of a seemingly unstoppable black market.

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